i
1----
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-0001
REC,E\VE~
but
\2 Ob PH '96
2
p,;.;b$y$$s~
Special
Services
Fees
and Classifications)
Docket
No.
: (
MC96-3
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL
WITNESS PAUL M. LION
(OCA/USPS-T4-27-37)
(August
2, 1996)
Pursuant
the
,,4--.
Postal
hereby
Rate
submits
documents.
the
to
United
incorporated
sections
Commission,
25 and
the
interrogatories
Instructions
States
Postal
26 of
Office
the
of
the
and requests
included
with
Service
dated
of
Practice
Consumer
for
OCA Interrogatories
June
19,
1996,
GAIL WILLETTE
Director
Office
of the
submitted,
Consumer
DAVID RUDERMAN
Attorney
Advocate
<of
Advocate
produc,tion
by reference.
Respectfully
,,I-.
Rules
of
1-4
are
her,eby
to
:
Docket
No.
MC96-3
2
. ,.--
Refer
OCA/USPS-T4-27.
a.
Please
explain
costs
necessary
What
to
attributable
C.
r-
post
the
percent
of
explain
the
a.
b.
OCA/USPS-T4-15(d).
of
Delivery
Please
impossible.
do you
cost
of
Delivery
Group
box
rationale
identify
E
any
data
calculations.
contrary
post
Group
for
costs
of
office
Delivery
box
not
that
E is
attributable
cost
have
the
not
1.6
percent
for
the
'test
Group
E is
attributable
treating
year?
1.6
Please
costs.
these
of
cost,s
as
costs.
Refer
which
to
presents
LR-SSR-104
updated
in
caller
this
proceedin'g,
service
and USPS
costs
for
Docket
R90-1.
Please
list
caller
servic!e
material
or
Please
provide
the
,.r-.
to
the
total
OCA/USPS-T4-28.
No.
calculation
attributable
institutional
response
to
office
Assume
LR-F-180,
is
make the
evidence
total
your
why the
attributable
b.
to
each
studies,
item
costs
analyses
incorporated
in
LR-SSR-104
conducted
an estimate
materials
in
or
of
in
the
analyses
that
the
calculation
is
FY 1979
time
based
or
on studies,
earlier.
and cost
referred
of
to
to
in
update
"a"
above.
‘I
Docket
No.
MC96-3
3
OCA/USPS-T4-29.
LR-F-180,
No.
a.
Refer
which
presents
this
caller
confirm
that
the
average
8.1851
minutes
used
to
determine
functions
based
on data
F-180.
If
Please
proceeding,
service
costs
used
and USPS
Docket
,Eor
for
materials
or
See Docket
Analysis
Please
for
identify
Caller
any
separation
No.
in
data
using
of
in
the
R90-1,
window
LR-SSR-104
time
per
was
as LR-
separ.ation
cost
of
window
in
LR-F-180
conducted
in
USPS LR-F-180,
Service,
service-
explain.
service
analyses
of
methodology
same
please
caller
LR-SSR-104
cost
the
average
used
separation
service
determine
functions
on studies,
per
to
the
caller
the
per
time
confirm,
whether
minutes
Cost
do not
explain
earlier?
for
and computed
you
accounting
C.
updated
in
Please
8.19
/--.,
LR-SSR-104
R90-1.
accounting
b.
to
February
to
calculate
that
have
of
serviceis
FY 1979
Update
1990
the
based
at
or
of
11.
average
time
been
updated
since
the
average
time
been
updated
since
1979.
d.
For
any
data
separation
the
1979,
not
updated
used
in
the
LR-SSR-104
please
for
in
identify
this
calculation
that
the
proceeding.
of
have
not
data
and explain
why they
per
were
Docket
MC96-3
NO.
4
OCA/USPS-T4-30.
average
a.
time
What
Refer
per
to
were
taken
determined
Please
minutes?
Exhibit
II,
concerning
the
separation.
efforts
separation
LR-SSR-104,
to
in
verify
that
LR-SSR-104
explain
any
the
is
such
average
currently
efforts
time
per
8.1851
and provide
any
documentation.
b.
,*-.
If
no efforts
were
believing
that
remains
accurate.
which
LR-F-180,
No.
a.
the
please
average
Refer
OCA/USPS-T4-31.
taken,
to
of
8.1851
LR-SSR-104
presents
updated
explain
in
caller
your
minutes
this
basis
per
for
separation
proceeding,
service
costs
and USPS
for
Docket
R90-1.
Other
of
than
large
the
and
hourly
large
computed
not
of
and
small
using
confirm,
firms,
small
determination
labor
window
firms
the
please
rate
please
of
confirm
and platform
in
same
LR-SSR-104
methodology
explain.
$23.939
and the
that
delivery
was based
as LR-F-180.
number
the
costs
for
on data
If
and
you
do
Docket
b.
No.
MC96-3
Please
explain
total
annual
small
firms
analyses
R90-1,
whether
in
LR-F-180
identify
f-.
any
data
used
identify
this
that
that
a.
of
What
Cost
to
for
updated
the
for
the
l,arge
and
materials
or
See Docket
Analysis
calculate
for
have
been
not
for
and
since
No.
Caller
total
annual
small
firms
in
firms
in
1979.
of
total
large
updated
and explain
the
large
calculation
costs
Refer
to
separations
efforts
separations
any
been
delivery
data
earlier?
dIerive
annual
and small
since
why they
were
the
1979,
not
please
updated
proceeding.
OCA/USPS-T4-32.
number
used
costs
in
costs
on studies,
or
of
to
12-13.
data
have
window/platform
LR-SSR-104
at
delivery
that
based
FY 1979
1990
used
delivery
Update
any
window/platform
For
in
February
LR-SSR-104
calculations
are
USPS LR-F-180,
Please
d.
the
window/platform
conducted
Service,
C.
5
such
per
were
per
efforts
LR-SSR-104,
1,
concerning
the
caller.
taken
caller
page
to
is
and provide
verify
currently
that
the
2.32?
any documentation.
number
of
Please
explain
for
Docket
. _r-.
b.
No.
If
MC96-3
6
no efforts
were
separations
per
taken,
caller
please
explain
was not
why the
reevaluated
for
:number
of
this
proceeding.
C.
If
no efforts
believing
were
that
the
taken,
please
2.32
explain
your
per
caller
separations
basis
for
remains
accurate.
OCA/USPS-T4-33.
Refer
determination
a.
/---
of
storage
What
efforts
feet
allocated
Please
to
were
explain
LR-SSR-104,
costs
for
page
caller
taken
to
verify
per
firm
is
currently
any
such
efforts
6,
concerni,ng
the
service.
that
the
4.1
number
square
and provide
of
square
feet?
any
documentation.
b.
If
no efforts
square
feet
were
please
taken,
allocated
per
firm
explain
was not
why the
number
reevaluated
for
of
this
proceeding.
C.
If
no efforts
believing
that
remains
accurate.
calculation
the
Refer
OCA/USPS-T4-34.
,,.--.
were
of
attributable
taken,
4.1
to
please
square
feet
LR-SSR-104,
costs
for
explain
your
allocated
Exhibit
caller
basis
per
I,
firm
concerning
service.
for
the
Docket
a.
No.
7
Please
confirm
number
of
not
b.
MC96-3
confirm,
used
in
In
determining
the
why the
by 2.32
to
cost
of
$667.08
caller
OCA/USPS-T4-35.
Information
average
administered
average
No.
post
to
Refer
rental
service
it
does
fee.
caller
service
per
cost
explain
used
caller
of
why the
to
costs.
per
is
call
$207.54
calculate
please
$667.08
$287.54
you
and why
costs,
of
the
If
represent
attributable
cost
cost
response
your
1,
question
office
by non-city
OCA/USPS-T4-36.
represents
divided
number
amount
rather
the
att,ributable
Presiding
Officer's
service.
Request
of
service
amount
Refer
number
of
Please
separation.
the
calculation
an annual
100,770
a caller
what
annual
reach
pay
of
explain
caller
explain
figure
that
please
is
than
the
entities
it
or
the
that
to
installed
square
provide
the
in
contract
offices
5.
Please
provide
offices.
LR-SSR-119,
per
Please
8.
boxes
delivery
to
at
foot
page
for
Delivery
Group
III.
do
Docket
,,-‘--.
No.
WA/USPS-T4-37.
LR-SSR-119.
SSR-119
attributable
,,.-..
MC96-3
8
Refer
Please
was used
costs.
in
to
your
confirm
the
If
responses
that
calculation
you
do not
the
to
sheet
of
post
confirm,
OCA/USPS-T4-lo-11
entitled
"CR&"
office
box
please
explain.
and
in
LR-
1
,‘---
Docket
No.
MC96-3
CERTIFICATE
I hereby
document
accordance
upon
certify
all
with
that
I have
participants
section
3.B(3)
OF SERVICE
this
date
of
record
of
the
in
served
this
special
DAVID RUDERMAN
Attorney
Washington,
August
2,
D.C.
1996
20268-0001
the
foregoing
proceeding
rules
of
in
practice.